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SEC Comment Letter for DANA INC (DAN) (CIK 0000026780) (DAN) — Oct 2, 2012

DANA INC (DAN) (CIK 0000026780)
Date: Oct. 2, 2012 · CIK: 0000026780 · Accession: 0000000000-12-054329

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: August 23, 2012

Date
October 2, 2012
Author
/s/ Cecilia Blye
Form
UPLOAD
Company
DANA INC (DAN) (CIK 0000026780)

Letter

October 2, 2012 Via E -mail Roger J. Wood President and Chief Executive Officer Dana Holding Corporation 3939 Technology Drive Maumee, OH 43537

Re: Dana Holding Corporation Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 2 3, 2012 File No. 1 -01063

Dear M r. Wood :

We refer you to our comment letter dated August 23, 2012 regarding business contacts with Syria. We have completed our review of this subject matter. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filin g to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Cecilia Blye

Show Raw Text
October  2, 2012

Via E -mail
Roger J. Wood
President and Chief Executive  Officer
Dana Holding Corporation
3939 Technology Drive
Maumee, OH 43537

 Re: Dana Holding Corporation
  Form 10-K for the Fiscal Year Ended December 31, 2011
  Filed February 2 3, 2012
  File No. 1 -01063

Dear M r. Wood :

We refer you to our comment letter dated August 23, 2012 regarding business contacts
with Syria.  We have completed our review of this subject matter.  We remind you that our
comments or changes to disclosure in response to our comments do not foreclose the
Commission from taking any action with respect to the company or the filing and the company
may not assert staff comments as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.  We urge all persons who are
responsible for the accuracy and adequacy of the disclosure in the filin g to be certain that the
filing includes the information the Securities Exchange Act of 1934 and all applicable rules
require.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Max Webb
  Assistant Director
 Division of Corporation Finance